Short answer: a sterile, absorbable surgical haemostat is classified in HS 3006.10, not 3005.90. The legal basis is Note 4 to Chapter 30, which lists "sterile absorbable surgical or dental haemostatics" as goods that heading 3006 covers. In practice the base duty is low - Free under the US HTS line 3006.10.01.00, and 0% third-country duty under the EU's 3006 10 90 - which means the money and the delay usually sit somewhere else: origin-based additional tariffs, import VAT, and a misdeclaration that stops the shipment.
This page covers the classification test, the four tariff lines that matter, and the documentation that keeps a hemostat shipment moving.
The classification test: three questions
| Question | If yes | If no |
|---|---|---|
| Is the product sterile? | Continue | Likely Chapter 30 exclusion - check 3005 |
| Does it act as a haemostatic, i.e. accelerate clotting at a surgical site? | Continue | A plain dressing goes to 3005.90 |
| Is it absorbable, left in the body to resorb? | 3006.10 | Non-absorbable haemostatic dressing: check 3005.90 |
Two of the three are usually easy. The one that causes disputes is the second: a gauze that is merely absorbable but makes no haemostatic claim is not a 3006.10 product, and a powder that makes a haemostatic claim is not a generic chemical preparation in 3824.
Which form does your product take?
| Product form | Heading | Reasoning |
|---|---|---|
| Knitted ORC gauze, sterile, absorbable | 3006.10 | Sterile absorbable surgical haemostatic |
| Absorbable haemostatic particles / powder, sterile | 3006.10 | Same legal description; form does not change the heading |
| Collagen or gelatin sponge, sterile, absorbable | 3006.10 | Same |
| Non-absorbable haemostatic gauze (e.g. kaolin-coated) | 3005.90 | Haemostatic but not absorbable - dressing heading |
| Plain cotton gauze, no haemostatic claim | 3005.90 | Wadding and gauze, not a haemostatic |
| Bulk ORC fibre, not sterile, not a finished device | Chapter 39 / 29 as applicable | Heading 3006 requires a finished sterile article |
The legal basis, in one paragraph
Chapter 30 Note 4 states that heading 3006 applies only to a closed list, and that list includes "sterile absorbable surgical or dental haemostatics." The heading text repeats it: "Sterile surgical catgut, similar sterile suture materials (including sterile absorbable surgical or dental yarns) and sterile tissue adhesives for surgical wound closure; sterile laminaria and sterile laminaria tents; sterile absorbable surgical or dental haemostatics; sterile surgical or dental adhesion barriers, whether or not absorbable."
Two consequences follow. First, the classification is driven by legal description, not marketing language - "absorbable hemostat" is literally in the heading. Second, because Note 4 is exhaustive, a product that does not meet the description cannot be pushed into 3006 by analogy.
The four tariff lines that matter
| Market | Line | Base duty | What overrides the base rate |
|---|---|---|---|
| United States | HTS 3006.10.01.00 | Free (general rate) | Chapter 99 additional duties by origin - Section 301 and other measures applied to Chinese-origin goods have changed repeatedly; check the current Chapter 99 subchapter at time of entry |
| European Union | TARIC 3006 10 90 (Other; 3006 10 10 is catgut, 3006 10 30 adhesion barriers) | 0.000% third-country duty, erga omnes | Import VAT at the member state rate; anti-dumping or safeguard measures if any apply to the origin |
| Japan | HS 3006.10 | Confirm in Japan Customs' current tariff schedule | EPA rates by origin; consumption tax at import |
| Brazil | NCM 3006.10.00 | Confirm current II rate with Receita Federal | II + IPI + PIS/COFINS-Importação + state ICMS; ANVISA registration must be consistent with the declared NCM |
Two honest caveats. US: the HTS general rate being Free does not mean zero cost - the additional tariff layers applied to Chinese-origin goods since 2018, and again in 2025–2026, are origin-based and revised often, so the entry line, not the article, is authoritative. Brazil and Japan: tariff levels and ex-tarifário programmes change by decree; pull the rate at shipment rather than from a supplier brochure.
Where the duty is genuinely zero, your landed cost is dominated by something else:
Import VAT - EU member states apply their own rate; it is recoverable for VAT-registered importers but it is cash out first.
Brazil's cascading taxes - II, IPI, PIS/COFINS-Importação and ICMS compound, so a nominally low tariff line can still produce a high landed cost.
Freight and cold-chain - not applicable to most hemostats, but volumetric weight on bulky gauze is.
Clearance delay - the real cost of a misdeclaration is demurrage and a held consignment, not the duty difference.
Registration amortisation - a five-figure registration cost spread across annual volume often exceeds the duty line entirely.
What to write on the commercial invoice
Customs does not read your brochure. It reads the invoice description and the accompanying certificate. A description that survives scrutiny names the article, the material, the sterility and the heading:
"Sterile absorbable haemostatic gauze, oxidised regenerated cellulose, knitted, single use, for surgical haemostasis - HS 3006.10"
For particles:
"Sterile absorbable haemostatic particles, plant-starch derived, single use, for surgical haemostasis - HS 3006.10"
Avoid descriptions that only name a brand, that say "medical supplies," or that copy a competitor's wording. Each of those invites a classification query that costs more time than the duty ever would.
Attach, at minimum: the IFU, the certificate of conformity or registration for the destination market, the sterilisation statement, and a certificate of origin if you are claiming a preferential rate.
Six misclassification errors and what they trigger
Declaring ORC gauze as 3005.90. Understates the product's identity; may conflict with the registration dossier and can void a haemostatic claim during a tender.
Declaring haemostatic powder under 3824. Common when the shipper reads "starch" and classifies it as a chemical preparation. It is a sterile finished device.
Using 3006.10 for non-absorbable haemostatic gauze. The heading requires absorbability; a kaolin dressing does not meet it.
Declaring bulk material as a finished device. Heading 3006 requires a sterile finished article.
Origin claimed but not documented. A preferential rate without a valid origin declaration is recoverable duty plus penalty, years later.
NCM/HS inconsistency with the health-authority registration. In Brazil and several other markets, the registration dossier records a classification; a different code at entry creates a mismatch that blocks clearance.
How to lock the classification down
US: request a binding ruling from CBP, or check the CROSS ruling database for a materially identical product.
EU: apply for a Binding Tariff Information (BTI) decision in one member state; it binds customs across the Union for its validity period.
Brazil: request a Solução de Consulta from Receita Federal - the only way to make the NCM position durable against a later assessment.
Japan: use the Japan Customs tariff classification inquiry before the first shipment.
These take weeks, not days. Do them once, before the first container, not after the first penalty notice.
FAQ
Is an absorbable hemostat HS 3006.10 or 3005.90? 3006.10. Chapter 30 Note 4 lists sterile absorbable surgical or dental haemostatics under heading 3006, and absorbability is what separates it from the 3005 dressing heading.
What is the US duty on absorbable hemostats? HTS 3006.10.01.00 carries a general rate of Free. Additional Chapter 99 duties may apply depending on country of origin, so confirm the applicable subchapter at the time of entry.
What is the EU duty on 3006 10 90? 0.000% third-country duty for all origins without a preferential agreement. Import VAT still applies at the member state rate.
Does a hemostatic powder go in a different heading from gauze? No. The heading covers the article's function and sterility, not its physical form, so sterile absorbable haemostatic particles and knitted gauze share 3006.10.
Can I use 3005.90 for a kaolin-coated gauze? Yes, if it is not absorbable. The 3006.10 description requires the product to be an absorbable haemostatic; a non-absorbable haemostatic dressing stays in 3005.90.
Does the HS code affect my registration? It can. Several authorities record a classification in the registration dossier, and a mismatch between the declared code and the dossier is a common cause of clearance holds.
Can a supplier's stated HS code be trusted? Treat it as a starting point. The binding answer comes from a customs ruling in the destination market, and the ruling is tied to a specific product description.
Key takeaways
3006.10 is the correct heading for sterile absorbable haemostats; 3005.90 is for non-absorbable dressings.
Base duty is low - Free in the US, 0% in the EU - so origin-based additional duties, VAT and clearance delays drive the real cost.
Invoice wording carries the classification; write the article, material, sterility and heading explicitly.
A binding ruling before the first shipment is cheaper than a dispute after the third.
Tariff rates and additional measures change by regulation and by origin. Confirm the rate and any Chapter 99 or safeguard measure at the time of entry; this article is not customs advice.
References
World Customs Organization - HS heading 3006 and Chapter 30 Note 4 (as reproduced in the EU Combined Nomenclature explanatory notes and national tariff schedules)
U.S. International Trade Commission - HTS 3006.10.01.00
European Commission - TARIC, EU Customs Tariff
TARIC line 3006 10 90 - third-country duty 0.000%, erga omnes (data updated 2026-08-08)
Japan Customs - tariff schedule
Receita Federal do Brasil - NCM 3006.10.00 and import taxation rules